Interpretation ID: nht73-3.42

DATE: 03/08/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Wiggins & Christian

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 27, 1973, concerning the application of the new Federal Odometer Disclosure Requirements to transfers between dealers.

The Federal requirements apply, with certain exceptions, to each transfer of ownership of a motor vehicle. Some types of vehicles, such as heavy trucks and antique vehicles, are exempt. Passenger cars and lighter vehicles, however, are exempted only in the case of transfers of new vehicles from a manufacturer or a distributor to a dealer or from one dealer to another. The transfer of a used car or light truck, whether from dealer to dealer, dealer to wholesaler, or dealer to customer, must be accompanied by a disclosure statement.

ENC.